Payment, OASIS & HHVBP Changes?!?

CMS Proposes MAJOR Changes for Home Health in the 2024 Proposed Rule. Here's what they mean for YOU and your agency!

Payment Changes:

First, let's get the bad news out of the way: More cuts. Remember when CMS said last year that they "needed to cut" by 7.85%, but they gave us some grace and only took about half of that? Well, this year they propose to take the rest of this cut at a rate reduction of 5.653%. After the adjustment for the cost of inflation, the final impact for a 30-day Home Health PDGM base payment will be $1,974.38, a decrease from this year's base payment of $2010.69. CMS will also "recalibrate" the case-mix items to be more reflective of costs for agencies. This is just the little "shell game" that CMS performs on our case mix of diagnoses and functional item weights each year, and it is "budget neutral".  Now, onto other news...

 

Home Health Value Based Purchasing Program (HHVBP):

CMS is proposing to remove five quality measures from HHVBP:

(1) OASIS-based Discharge to Community; 

(2) OASIS-based Total Normalized Composite Change in Self-Care (TNC Self-Care); 

(3) OASIS-based Total Normalized Composite Change in Mobility (TNC Mobility); 

(4) Claims-based Acute Care Hospitalization During the First 60 Days of Home Health Use (ACH); and

(5) Claims-based Emergency Department Use without Hospitalization During the First 60 Days of Home Health Use (ED Use).


In place of these retired measures, CMS is proposing to add the following measures: 

(1) The claims-based Discharge to Community-Post Acute Care (DTC-PAC) Measure for Home Health Agencies; 

(2) The OASIS-based Discharge Function Score (DC Function) measure; and 

(3) The claims-based Home Health Within-Stay Potentially Preventable Hospitalization (PPH) measure.


CMS is proposing to make all changes to the applicable measure set discussed in this rule beginning with the CY 2025 performance (calendar) year, thus all changes will affect the same payment year beginning with the CY 2027 payment year.

Since we would then have two less measures, CMS is proposing to adjust the weights for the measures in the OASIS-based and claims-based measure categories starting in CY 2025. Lastly, CMS is proposing to update the Model baseline year to CY 2023 for all measures starting in CY 2025.

 

OASIS and Home Health Quality Reporting Program (HHQRP) Changes:

Our overall quality program (HHQRP) is also facing a little fruit cart upset, by proposing to remove two measures and add in four additional measures.  


CMS is proposing the removal of the following measures:

(1) Admission and Discharge Functional Assessment and Care Plan that Addresses Function 

ATTENTION! This means no more column 2 "Discharge goal" for GG0130 and GG0170!! That's correct-- we will no longer be required to report a Discharge Goal (that is, GG0130, Column 2 or GG0170, Column 2) on the OASIS beginning with patients admitted on April 1, 2024 (and this column will be removed at next OASIS revision).  

(2) Removal of M0110, Episode Timing and 2200 Therapy Needs. These items have been obsolete for some time since our episode timing for payment is driven by the claims system, and we are no longer reimbursed based on therapy need. 


CMS is proposing the public reporting of four measures:

(1) Discharge Function; CMS drives this based on our discharge GG self care and mobility items, and compares your patient's improvement to what was statistically expected for improvement. (NOTE: Important to lessen our use of the "not attempted responses" now! Try to decrease your 07, 09, 10 and 88 scores as much as accurately possible!) 

(2) Transfer of Health (TOH) Information to the Provider — Post-Acute Care (PAC) Measure (TOH-Provider); (based on the current transfer OASIS item) 

(3) Transfer of Health (TOH) Information to the Patient — Post-Acute Care (PAC); (based on the current DC OASIS item) 

(4) COVID-19 Vaccine:  Percent of Patients/Residents Who Are Up to Date. This one is a little vague.  We are unsure what CMS says about "Up to date" and what to do with any contraindications, etc.  A new OASIS item will have to be added, expected in January of 2025, simply asking "Is the patient up to date on COVID-19 vaccination-- __ Yes  __No." 


There were some additional changes related to lymphedema therapy and IVIG therapies being provided in the home setting, as well as enrollment changes, which we will cover in another newsletter as we get into all of the details. 

So, really, the only bad news here was the cut in payment. There is a bipartisan bill fighting for home care (Preserving Access to Home Health Act of 2023 (S. 2137)) and I urge you to reach out to your representatives in Congress and ask them to support this bill and the future of home health.  


As always we thank you for all you do- and look forward to supporting your work in anyway we can!